I Got a FARM Corrective Action. Now What?

 

The Farmers Assuring Responsible Management (FARM) Animal Care Version 4 rolled out January 2020. As dairies have their farms evaluated with this new version, there may be questions about corrective actions. This article will outline corrective actions within FARM Animal Care evaluations, the timeline of each corrective action, and provides examples for corrective actions. Finally, there is a summary table of corrective actions.

 

The FARM program refers to dairy farms as “facilities” in their documents. In this article, we will not use the term facilities, but dairy or farm interchangeably. 

 

It is critical to reach out directly to your FARM Evaluator, co-op, and/or processor with questions or concerns regarding specific corrective actions and the timelines laid out for you. The FARM Evaluator should clearly communicate program expectations and the timeline for resolving corrective actions upon completion of your dairy’s evaluation. Before your evaluator leaves your farm clarify how they will communicate with you regarding the resolution of any corrective actions - emails, phone calls, mailing copies of items, or an in-person follow-up visit. You should receive a copy of your report which summarizes the findings of the evaluation.

 

 

 

Immediate action plans require that a standard is met immediately. In Version 4, the only criterion that initiates an IAP is continuing to routinely dock tails. If a dairy fails to meet this standard, it will be placed on Conditional Certification for 48 hours, or less, until the standard is met. Upon resolving the IAP (i.e. stop tail docking), the dairy will be placed back in good standing and be considered Certified. If the standard is not met within 48 hours, the farm will be Conditionally Decertified until the standard is met.

 

Even if the IAP is resolved within 48 hours, Evaluators will follow-up at 1-week, 1-month, and 3-month intervals to ensure the standard continues to be met. Producers need to be cognizant that if they choose to become Conditionally Decertified, a FARM participant, who is the co-op or processor, will not be able to procure milk from the facility.

 

 

When an MCAP is received, the issue must be resolved within 9 months of the evaluation. If the issue is not resolved within 9 months or the timeline determined by the processor or coop, the dairy will be placed on Conditional Certification. Upon resolving the MCAP, the dairy will be placed back in good standing and be considered Certified.

 

The animal care standards within the MCAPs include:

Example: The Evaluator observes the dairy has a Herd Health Plan that has not been reviewed and signed in the last year by their veterinarian of record. The Evaluator also observes calves older than three days did not have water. Lastly, the existing written protocol for when newborn calves receive colostrum and how much is not being implemented by employees as written in the protocol. The Evaluator issues three MCAPs for this dairy: 1) Herd Health Plan needs to be signed annually by the veterinarian of record; 2) calves older than three days need to have access to water; 3) the written protocol and how employees implement the newborn calf feeding practices need to match. The Evaluator determines all three of these corrective actions need to be resolved in 6 months instead of the maximum 9-month time limit. The Evaluator will visit the farm 6 months after the corrective actions were issued to ensure these three items were resolved.

 

 

This corrective action needs to be resolved in three years or less as determined by your Evaluator. If the action is not resolved in the determined amount of time, the dairy will be placed on Conditional Certification leading to Conditional Decertification if standards remain unmet after the designated time frame. Upon resolving the CIP, the dairy will be placed back in good standing and be considered Certified.

 

The animal care standards within the CIPs include:

Example: During the same evaluation described above, the Evaluator read in the written protocols that pain mitigation is to be used when disbudding calves; however, employees were disbudding without pain mitigation. Also, there is no record of continuous education for family employees performing calf care tasks. The Evaluator issued two CIPs: 1) the written protocol and practice for disbudding calves need to match and 2) family employees will receive annual continuous education in their respective areas of work. The Evaluator determines the deadline to resolve the pain mitigation for disbudding within two years and documentation of annual continuous training within three years.

 

Given this dairy’s evaluation example, the Evaluator will follow-up with the dairy farm in 6 months to verify the herd health plan is reviewed and signed by the veterinarian of record, calves older than three days of age have access to water, and the protocols and practices for calf care match. Additionally, the Evaluator will follow-up with the dairy two years after the evaluation to verify the written protocol and practices for disbudding match. The CIP for annual continuous education of family employees would be verified during the next routinely scheduled FARM Evaluation since on-farm evaluations are performed on a three-year rotation. At each visit, the Evaluator will only verify the corrective action items which are due.

 

 

 

A dairy farm is considered certified in the FARM Animal Care Program if it:

 

To help decrease the chance of receiving any corrective action plans, take the time to prepare for your evaluation. A summary article is also available in Preparing for FARM Animal Care Evaluations, but it is only the starting point in preparing for your FARM Animal Care Evaluation. We encourage you to consult with your FARM Evaluator or co-op/processor representative and review any previous evaluation reports for your farm. Additional FARM Animal Care Version 4 resources and downloadable templates, available in English and Spanish, can be accessed at the National Dairy FARM website.

 

Table 1 provides a summary of each corrective action, standards that trigger each corrective action and the maximum amount of time to resolve each corrective action.

 

 

 

The FARM Program recommends the temporary suspension of all 2nd-party evaluations by FARM participants (i.e. processors/coops) until May 1, 2020. Due dates associated with evaluations and existing corrective action plans will be extended until at least Friday, May 22, 2020. All MCAPs and CIPs with deadlines through May 1 will be extended by at least three weeks once normal activities resume. However, if MCAPs or CIPs are related to documentation issues (e.g. records or protocols) and electronic communications between the FARM Evaluator and the dairy can resolve the issue, please be prepared to follow-up on established timelines if requested. Any Willful Mistreatment incidents will continue to be handled on a case-by-case basis while protecting everyone’s health and safety during this time. All farm tours for customers, brands, or the general public should be cancelled or offered in another format, such as a virtual tour. Anyone with questions should contact the National Dairy FARM Program.